Compliance verification activity type: Field Inspection
Team:
Regulated company: Alliance Pipeline Ltd.
Operating company: Alliance Pipeline Ltd.
Province(s) / Territory(s):
Discipline(s):
Rationale and scope:
Verify liaison and continuing education program through meetings with the company and response parties.
Compliance tool(s) used:
Facilities:
Facility Types
Life-cycle Phases
Regulatory requirements that apply to this activity:
Observation 1 - Introductory Comments
Date & time of visit: 2019-03-07 09:00
Discipline: Emergency Management
Categories:
Facility:
Observations:
NEB staff met with first response agencies,and emergency planners, to assess the implementation and the effectiveness of Alliance Pipelines liaison, consultation and continuing education activities as required under sections 33 – 35 of the National Energy Board Onshore Pipeline Regulations. The NEB’s expectations are outlined in the Guidance Notes for the National Energy Board Onshore Pipeline Regulations (OPR) (https://www.neb- one.gc.ca/bts/ctrg/gnnb/nshrppln/gdncntnshrpplnrgltn-eng.html).NEB staff traveled through the north east of British Columbia and into Alberta to meet with fire departments and emergency planners in order to ensure the company was meeting their requirements under the Onshore Pipeline Regulations (OPR), sections 33, 34 and 35. These sections outline the requirements a company has in maintaining ongoing educational efforts with responding agencies, training opportunities, and messaging to communities in areas that may be impacted by an incident on their pipeline. Staff then later met with Alliance Pipeline at their office in Grande Prairie, AB.The specific communities that NEB staff met with were: Fort St. John Fire Department, Taylor Fire Department, Charlie Lake Fire Department, Peace River Regional District, Grovedale Fire Department, County of Grande Prairie, and the City of Grande Prairie.In discussions with Alliance, they described the relevant agencies they engage with, and outlined the approach they take that enables them to offer continuing education and consultation opportunities with emergency officials that have jurisdiction through which the APL facility transects. This approach typically includes meeting once every three years. These meetings are conducted in a variety of formats including training sessions, presentations, visitations, trade shows, and exercises. In addition to these, Alliance provides its emergency response plan to those who may be impacted or involved in a response, distributes various informative brochures and pamphlets, annual mail outs and conducts effectiveness and capability surveys. Key information that is conveyed during these meetings includes the release consequences, exclusion zone, and the unique attributes associated with the Alliance pipeline and facilities.Alliance has indicated that for the most part stakeholders and emergency officials along the pipeline rarely initiate contact but any feedback or requests that are received are considered and incorporated in the same manner regardless of who initiated the liaison and result in a work order being generated through the Landscribe system (Database). The Company also has memberships in cooperatives such as TIMAG. It was noted by a number of emergency officials that cooperatives such as TIMAG would often provide information sessions or check in with the fire departments or emergency planners.During the inspection interviews, local communities discussed the relationship they have with the oil and gas companies in the area, with discussion focusing on Alliance and their outreach efforts. The feedback gathered was generally positive, with the communities reporting they were happy with the level of interaction they had with the company, and were able to provide us with the recent ERP of the company for their region. They also discussed with NEB staff how they were invited to, or informed of, exercises the company carried out in their area, but mentioned they often did not have time or resources to send to those exercises, as many other industrial partners also sent invites. Each agency described a clear understanding of their expected roles and responsibilities in the event of an emergency and felt that the level of consultation was appropriate, with there being no noted gaps in information exchange, and if they did have a need for additional information they were comfortable reaching out to Alliance and had the contacts to do so.
Compliance tool used: No compliance tool used
Observation 2 - Liaison
In discussions with the related fire departments, each department reported feeling confident in the comany's ability to respond independantly, and also knowing where they would fit into the response structure, if applicable.Typically, the company has staff in the communities the NEB visited on a fairly regular basis. During these times staff will occasionally make time to stop in to meet with agencies, and more formal arranged meetings are also planned at times. All agencies made the same comment that they were informed of exercises when they took place, though due to staff or resource limitations they could not possibly attend all invitations.All discussions with the local fire services and information sharing appears to conform with Alliance's ERP, namely sections 6.7.1 (Crisis Managmenet Cmmunications Plan), 7.6 (Communicaitons Section), and 7.6.2 (External Communications).
Observation 3 - Continuing Education
Date & time of visit: 2019-03-07 12:00
The fire departments and emergency planners that NEB staff interviewed reported feeling more knowledgeable in the company's Emergency Management system and how they fit into that system. Events hosted by Alliance in the communities were deemed well received and most felt that the company was very proactive and working well at the local level with them. The question posed to them was it they felt their level of understanding and awareness continues to increase each year that they interact with the company. Each fire department and emergency planner agreed their understanding was continuing to increase, indicating a successful continuing education process by the company. Of note, some of the fire personnel we met with made mention of other industry in the area and the more prominent concerns they had with them, as those industries / entities had not made similar efforts as ther pipeline company's in the area, and presented a serious potential hazard to the community in the event of an incident from them. Additionally, there was a general agreement that the size of Alliance contributed to their efforts to be proactive and engage in regular consultation and liaison activities and some expressed an underlying comfort with the company themselves as they felt they were more capable than most when it came to dealing with an incident. This all seems to further indicate the positive results of the efforts that Alliance is making.
Observation 4 - Interoperability
Date & time of visit: 2019-03-07 14:00
Due to the apparently successful efforts of the company in the area, there should be a high level of interoperability between responders and the company in this area. As the incident management system used is ICS, NEB staff also will be able to integrate into an ICP with Alliance Pipelines.Local organizations stated they were confident in their ability to integrate into an Alliance response. All interviewed staff had multiple years experience in emergency response or management, further suggesting that all participants would be able to work effectively in an ICP.
Identified non-compliances to company plans or procedures are non-compliances either to:
- the condition of an authorization document that requires the implementation of that plan or procedure; or
- the relevant section of the regulations that requires implementation of that plan or procedure including those sections that require implementation of plans or procedures as a part of a Program